U.S. v. Sandidge

Dist. Ct. imposed as one condition of supervised release prohibition on defendant’s “excessive use of alcohol,” which was defined as including “any use of alcohol that adversely affects defendant’s employment, relationships or ability to comply with conditions of supervision.” While defendant argued that said definition was impermissibly vague, Ct. of Appeals generally affirmed said condition, but substituted term “materially adversely affects” for “adversely affects” in original definition, since original definition raised concerns about fair notice to defendant, as well as arbitrary enforcement on alcohol-related conditions of supervised release.